TITLE:  Accurate Automation Corporation, B-292403; B-292403.2, September 10, 2003
BNUMBER:  B-292403; B-292403.2
DATE:  September 10, 2003
**********************************************************************
Accurate Automation Corporation, B-292403; B-292403.2, September 10, 2003

   DOCUMENT FOR PUBLIC RELEASE                                                
The decision issued on the date below was subject to a GAO Protective      
Order.  This redacted version has been approved for public release.        

   Decision
    
Matter of:   Accurate Automation Corporation
    
File:            B-292403; B-292403.2
    
Date:              September 10, 2003
    
Tenley A. Carp, Esq., and Karen Yankosky, Esq., McGuireWoods, for the
protester.
Mark D. Colley, Esq., Christopher R. Yukins, Esq., Caitlin K. Cloonan,
Esq., and Stuart Turner, Esq., Holland & Knight, for Raytheon Company, an
intervenor.
Barry L. Williams, Esq., Department of the Air Force, for the agency.
Paul I. Lieberman, Esq., and Michael R. Golden, Esq., Office of the
General Counsel, GAO, participated in the preparation of the decision.
DIGEST
    
1.  Under unrestricted solicitation that called for full and open
competition with no provision for award under small business innovation
research (SBIR) program or for any other small business preference, there
was no basis for agency to afford special assistance or differential
treatment to small business offeror, notwithstanding offeror*s erroneous
assertion in its proposal that it could be awarded an SBIR contract for
the requirement.
    
2.   Agency reasonably evaluated protester*s past performance as neutral
under  subcontractor management subfactor where protester lacked relevant
subcontractor management experience; the proposed large business
subcontractor*s past performance record in managing subcontractors cannot
reasonably be credited to small business protester as the prime
contractor, notwithstanding alleged mentor/protege agreement between the
two, since the evaluation subfactor is intended to assess the prime
contractor*s ability to supervise and control that mentor*s performance as
a major subcontractor.
    
3.  Agency reasonably determined that the significantly reduced technical
and past performance risk offered by technically superior proposal
warranted the payment of the associated evaluated cost premium under a
solicitation for a cost reimbursement contract for a complex system
development program which provided that the technical factors were
significantly more important than cost.
    
4.   Award determination, as well as underlying cost/technical tradeoff
vis-`a-vis protester, is unobjectionable even though focused on comparison
between awardee*s proposal and that of the next highest technically rated
proposal where, notwithstanding protester*s low evaluated cost, record
establishes propriety of evaluated technical superiority of awardee*s
proposal, and the protester*s proposal was reasonably evaluated as a
distant third.
DECISION
    
Accurate Automation Corporation protests the award of a cost reimbursement
contract to Raytheon Company under request for proposals (RFP)
No. F08635-03-R-0002, issued by the Department of the Air Force for the
system development and demonstration (including low rate initial
production (LRIP)) of the miniature air launched decoy (MALD). Accurate
asserts that its proposal was evaluated improperly and that the agency*s
determination to award to Raytheon is arbitrary and unreasonable.
    

   We deny the protest.
    
BACKGROUND
    
The solicitation was issued on January 14, 2003, with an amended February
25 closing date for receipt of initial proposals, on the basis of full and
open competition with award to be made to the offeror whose proposal
presented the *best value.*  The RFP stated that non-cost factors combined
were significantly more important than cost.  The RFP set forth four
evaluation factors, consisting of past performance and proposal risk,
which were equal in importance, and each of which was of greater
importance than the mission capability and *affordability* (cost) factors,
which were also equal in importance to each other. 
The solicitation also reserved the agency*s right to give evaluation
credit for proposed features better than stated desires or goals, and to
award to other than lowest price offeror.  RFP S: M-2(b).
    
The agency received four proposals including ones from [deleted] plus
those submitted by Accurate and Raytheon.  After performing initial
evaluations, the agency conducted discussions with all offerors during
which each offeror was provided with its past performance evaluations for
all of the programs that it had identified and any additional programs
that the performance risk assessment group (PRAG) had identified.  Each
offeror was also provided a complete copy of the interim assessment of its
past performance and asked to respond.  Contracting Officer*s Statement at
2.  Subsequently, requests for final proposal revisions (FPR) were sent to
each offeror, and FPRs were required by May 1.  After a final evaluation
was conducted by the evaluation team, each offeror was proffered an
opportunity (of which Accurate elected to avail itself) to discuss its
evaluation with the source selection authority (SSA) prior to the source
selection decision.  The agency made the award to Raytheon on May 21.
    
The evaluated probable total cost for the relevant proposals was: 
Accurate: $206,939,884; [deleted]; and Raytheon: $238,349,737.[2] 
Raytheon*s proposal received a final evaluation of exceptional/high
confidence (the highest possible assessment) under each of the three past
performance subfactors that were set forth in the RFP.  In this regard,
Accurate*s proposal was evaluated as neutral/unknown confidence under
subcontractor management, which the RFP specified as the most important
subfactor, and satisfactory/confidence under the other two past
performance subfactors.  Under proposal risk, for which there were three
equally important subfactors, Raytheon*s proposal was evaluated as low
risk under all three.  Accurate*s proposal was evaluated as low risk under
two of the factors and moderate risk under the third factor, *point of
departure design,* based on *the lack of legacy and maturity of the
[proposed] engine, payload and wing and tail folding/lock mechanism.*  AR,
Tab 6, Source Selection Decision, at 6-7.  Under mission capability, for
which there were three equally important subfactors, Raytheon*s proposal
was evaluated as blue/exceptional (the highest available rating) under two
and green/acceptable (the next highest rating available) under the third. 
Accurate*s proposal was evaluated as blue/exceptional under one subfactor
and green/acceptable under the other two.  However, the SSA determined
with respect to the one blue rating that the evaluation team had given
Accurate*s proposal under the point of departure design subfactor, that
Accurate*s proposal did not provide the additional benefits offered by
either the Raytheon or the [deleted] proposals, which derived from the
additional threat coverage offered by the [deleted] proposal, and the
significant reduction in logistic footprint, and the increased operational
utility and minimal development needed for enhancement to a specifically
contemplated jammer variant of the MALD which was offered by the Raytheon
proposal.  Id. at 9.   
    
The SSA performed a detailed comparison between the past performance, risk
and technical differences between the Raytheon and [deleted] proposals,
which had received close evaluation scores,[3] and determined to award to
Raytheon on the basis  that the Raytheon proposal provides *value in Past
Performance, Proposal Risk and Mission Capability, which far exceeds the
$15.5M [total cost] difference between [deleted] and Raytheon and the $31M
[total cost] difference between Accurate and Raytheon.*  Id. at 13.  While
the SSA specifically determined that the technical superiority associated
with Raytheon*s higher evaluated past performance, proposal risk and
mission capability was worth the $31 million cost premium associated with
the Raytheon proposal in comparison with the Accurate proposal, because of
the closeness of the Raytheon and [deleted] proposals, the SSA focused his
award determination on a comparison between the Raytheon and [deleted]
proposals.  The SSA explained this focus on the basis that while all four
proposals were technically acceptable, the Raytheon and [deleted]
proposals were so superior and close as to make the final selection
decision essentially a *two-horse race,* in which, despite its evaluated
low cost, Accurate*s proposal was *trailing the pack,* and out of the
*photofinish.*  Tr. at 236.  After receiving a debriefing on May 27,
Accurate filed this protest with our Office on June 6, and subsequently
supplemented its protest on July 21.
    
Accurate alleges primarily that the agency failed to give it any
evaluation credit to which it is allegedly entitled by virtue of its small
business status; that the past performance of Accurate*s team was
misevaluated; and that the agency*s cost/technical tradeoff and award
determination was arbitrary and irrational.
SMALL BUSINESS PREFERENCE
    
Accurate first contends that it was entitled to special *assistance* (that
is, an evaluation preference) because of its status as a small business
competing against large aerospace conglomerates under a solicitation for a
development program. Protester*s Comments at 3, 15.  Accurate further
asserts that cognizant Air Force officials orally assured Accurate that it
would receive such assistance by promising that the agency would *level
the playing field for a small business like Accurate.*  Tr. at 78.   In
this regard, Accurate also points to language in the Small Business
Innovative Development Act, 15 U.S.C. S: 638(a) (2000) (the Act), stating
that it is congressional policy *that assistance be given to small
business concerns to enable them to undertake and to obtain the benefits
of research and development in order to maintain and strengthen the
competitive free enterprise system and the national economy.*  Protester*s
Comments at 3-4.  Accurate points out that it stated in its proposal that
it sought the award as a phase III contract under the small business
innovation research (SBIR) program. 
    
SBIR Program
    
Accurate takes the position that the above-stated policy that assistance
be given to small businesses creates an overarching requirement that
procuring agencies favor small business competitors for research and
development contracts, and that this policy applies to the procurement at
issue.  This premise is misplaced.  The cited policy statement provides
the rationale for the establishment by the Act of the SBIR program, under
which certain federal agencies are required to reserve a portion of their
research and development funds for awards to small businesses.  As part of
its SBIR program, DOD issues an SBIR solicitation twice a year listing the
research topics for which it will consider SBIR program admission.  Firms
first apply for a 6‑month phase I award to test the scientific,
technical, and commercial merit and feasibility of a certain concept.  If
phase I is successful, the firm may be invited to apply for a 2-year phase
II award to further develop the concept.  After the completion of phase
II, firms are expected to obtain funding from the private sector and/or
non-SBIR government sources to develop the concept into a product for sale
in private sector and/or military markets.  See  DOD*s SBIR website,
; R&D Dynamics Corp.,
B-285979.3, Dec. 11, 2000, 2000 CPD P: 201 at 2.  Where an agency is
conducting an SBIR procurement, it has the discretion to determine which
proposals it will fund.  Microexpert Sys., Inc., B-233892, Apr. 13, 1989,
89-1 CPD P: 378 at 2.  
    
Here, while Accurate*s proposal indicates that it was under the mistaken
impression that the RFP was subject to an SBIR award, the simple answer is
that it was not; the RFP explicitly provided for full and open competition
and neither contemplated nor made reference to any possible SBIR award. 
The antecedent ALVIN contracts were also awarded on the basis of full and
open competition, not under the SBIR program.  The statutory policy
statement cited by Accurate does not provide an independent basis to make
an SBIR award under this procurement; to the extent that Accurate believes
that the procurement should have been conducted under the SBIR program,
the protest is untimely since it constitutes an alleged solicitation
impropriety which, under our Bid Protest Regulations, is required to be
filed prior to the initial closing time.  4 C.F.R. S: 21.2(a)(1) (2003). 
Accordingly, this protest basis is without merit.  
    
*Level Playing Field*

    
With respect to the Air Force*s alleged assurances that it would *level
the playing field for a small business like Accurate,* in the first
instance, the named Air Force officials all specifically deny having made
such assurances.  Thus, for example, the source selection evaluation team
chair testified:  *And I do remember telling all of the teams that we
expected this source selection to have a level playing field, not that we
would level the playing field.  And by saying level playing field, we
meant that everybody would be treated equally according to the
[solicitation] criteria.* Tr. at 78.
    
Based on the affidavits presented and the testimony at the hearing, we
find it more credible that Air Force personnel advised Accurate that the
evaluation would be conducted on a level playing field, and that Accurate
representatives naively understood this to mean that the Air Force would
afford it some sort of small business preference in order to *level the
playing field.*  However, there is no need to resolve this difference in
understanding of the particular language used or the intentions of the Air
Force procurement officials.  Regardless of what any Air Force official
may have said, the RFP did not call for any small business preference, or
for any particular manner of evaluation of small businesses different than
the evaluation of large businesses.  Accordingly, any verbal assurances
that Accurate believes it received in this regard are without effect.  The
unambiguous terms of the solicitation control, even if we assume,
arguendo, that agency officials provided conflicting oral advice; such
oral advice is not binding on the government, and an offeror relies on it
at its own risk.  Diamond Aircraft Indus., Inc., B-289309, Feb. 4, 2002,
2002 CPD P: 35 at 2.  In short, Accurate had no reasonable basis to
believe that it would receive any assistance or evaluation preference by
virtue of its small business status, and to the extent it believes that
RFP should have so provided, the allegation is untimely.
    
PAST PERFORMANCE 
    
The RFP provided that past performance on programs would be evaluated
under three subfactors, subcontractor management, systems engineering
performance, and integrated management, in descending order of
importance.[4]  The RFP stated that the past performance evaluation would
use the most recent and relevant performance data, and that the *offeror*s
entire team will be evaluated, including teaming partners or major
subcontractors.*  RFP S: M-1(3).  The RFP sought input from the offerors
in their past performance submissions, and also provided for evaluation
from other sources such as contractor performance assessment reports
(CPAR), Defense Contract Management Agency (DCMA) contracts, program
offices and other service and/or commercial organizations.  Id.   The
solicitation provided detailed and specific recency and relevance
criteria.  It also provided that each subfactor would receive a separate
assessment of the offeror*s present and past work record to indicate the
government*s confidence in the offeror*s ability to successfully perform,
with a rating range from exceptional/high confidence down to
unsatisfactory/no confidence, including the rating of neutral/unknown
confidence where there was an insufficient performance record available. 
Additionally, the RFP provided that the government would complete an
interim past performance evaluation that would be provided to each
offeror, and that during the past performance discussions the offerors
would have the opportunity to present information in response to the past
performance evaluations.  RFP S:S: M-1(3)(g),(h).  Accurate*s proposal was
evaluated as neutral under the subcontractor management subfactor and
satisfactory under the other two, while Raytheon*s proposal was evaluated
as exceptional under all three. 
    
Accurate contends that the agency failed to evaluate its *entire team,* as
required by the RFP, and in particular that the agency failed to
adequately consider the past performance record of General Dynamics, which
Accurate proposed as its major subcontractor, and with whom Accurate has a
mentor/protege agreement.
    
Subcontractor Management
    
In evaluating the subcontractor management subfactor, the agency
determined, and Accurate does not dispute, that only 8 percent of
Accurate*s total efforts involved any subcontracting, which was usually
performed by research institutions such as universities.  AR, Tab 8,
Proposal Analysis Report (PAR), at 18.[5]  The agency concluded that these
efforts were not sufficient to warrant an assessment and evaluated
Accurate*s subcontractor management as neutral.  Accurate contends that
the past performance of its proposed major subcontractor, General
Dynamics, should have provided a sufficient basis for a substantive
favorable evaluation under this subfactor, and was improperly ignored. 
The record shows that the Air Force did consider General Dynamics* past
performance under three programs, one of which was considered relevant,
and two of which were somewhat relevant.  General Dynamics* subcontractor
management was evaluated as neutral under two of these contracts, and as
exceptional under one of the somewhat relevant programs, but the PRAG team
concluded that this was not sufficient to warrant a team rating beyond
neutral.  This evaluation was presented to Accurate in the interim
evaluation, and Accurate neither disputed it nor provided any additional
past performance information to the agency in its FPR or in any other
proposal submissions or discussions.
    
In questioning the neutral assessment, Accurate focuses on the RFP
language that the entire team would be evaluated, and on its
mentor/protege agreement with General Dynamics.  In our view, these
arguments are misplaced.  Here, because of its unsuccessful experience
with the previous MALD program, the agency had placed substantial emphasis
on the importance of the past performance subcontractor management
subfactor, which was to assess *the offeror*s performance on relevant
efforts in relation to their management of subcontractors/suppliers and
the impact that subcontractor management had upon the overall success of
the program.*  RFP S: M-1(f)(1).  The purpose of this factor is to
evaluate the offeror*s likelihood of success as the prime contractor in
managing subcontractors in order to keep the program on track.  In these
circumstances, the proposed role of the team member whose past performance
is being assessed is relevant; it would be irrational and unreasonable to
consider, much less place emphasis on, the subcontractor management
experience of the very subcontractor whom the prime offeror will be
required to manage in performing this contract, irrespective of any
mentor/protege arrangement.  The fact that General Dynamics may have had
successful, relevant past performance in managing subcontractors has no
bearing on the performance risk associated with Accurate*s management of
General Dynamics as its subcontractor in performing this contract. 
Accordingly, the record provides no basis to object to the evaluation of
Accurate*s proposal as neutral under this subfactor.
    
Other Past Performance Subfactors
    
Accurate*s proposal was evaluated as satisfactory under both systems
engineering performance and integrated management performance, the other
two past performance subfactors.  The chief of the performance evaluation
team explained that the agency*s methodology was to first evaluate
Accurate*s past performance and arrive at an assessment, then to evaluate
the past performance of its proposed subcontractors and determine what, if
any, impact that assessment had on the overall team evaluation.  Tr. at
319-20, 339-40.  Accurate contends that the agency focused only on its
past performance without affording appropriate consideration to that of
its proposed subcontractors/team members.  Accurate variously asserts that
it had been assured that subcontractor past performance would be
considered equal in importance to that of the prime contractor in the
evaluation, that the agency failed to take into account the relative
percentage of work being performed by the subcontractors in performing its
evaluation, and that the entire team was not evaluated. 
    
It is not the function of our Office to evaluate past performance
information de novo.  Rather, we will examine an agency*s evaluation only
to ensure that it was reasonable and consistent with the stated evaluation
criteria and applicable statutes and regulations, since determining the
relative merit of offerors* past performance information is primarily a
matter within the contracting agency*s discretion.  Pacific Ship Repair
and Fabrication, Inc., B-279793, July 23, 1998, 98-2 CPD P: 29 at 3-4. 
Agencies are required to evaluate proposals consistent with the RFP*s
stated evaluation criteria, including considerations reasonably and
logically encompassed by the stated factors.  Gray Personnel Servs., Inc.,
B-285002, June 26, 2000, 2000 CPD P: 112 at 3.  Here, as to the alleged
verbal assurances that subcontractor past performance would be evaluated
as equal in weight to that of the prime, the solicitation does not so
provide and Accurate*s argument in this regard fails for the same reason
as is explained above with respect to its other contention regarding
verbal assurances that are inconsistent with the RFP.  With respect to the
agency*s methodology in evaluating the Accurate team and the specific
assessments, as with the subcontractor subfactor past performance
evaluation, consistent with the RFP terms (and with the agency*s
responsibilities under Federal Acquisition Regulation S:S: 15.305 and
15.306), the entire past performance evaluation and the underlying
rationale were presented to Accurate in full in the form of the interim
and final evaluations. Thus, Accurate was provided ample opportunity to
respond but failed to dispute the assessments or otherwise augment any
past performance information.  In these circumstances, Accurate*s
above-stated objections which were first raised after the award
determination do not provide a meaningful basis to call into question the
agency*s past performance evaluation.
    
In its comments on the hearing, Accurate for the first time asserted that
in its meeting with the SSA it did respond to the past performance
evaluation *by describing the depth and breadth of individual experience
of Accurate personnel in order to obtain a higher past performance
score.*  Protester*s Hearing Comments at 6.  Although an agency properly
may, in appropriate circumstances, consider the experience of supervisory
personnel in evaluating the experience of a new business, there is no
legal requirement for an agency to attribute employee experience to a
contractor as an entity.  The Project Mgmt. Group, Inc., B-284455, Apr.
14, 2000, 2000 CPD P: 66 at 4; Hard Bodies, Inc., B-279543, June 23, 1998,
98-1 CPD P: 172 at 4.  In our view, the protester has not provided any
meaningful basis to take exception to the agency*s past performance
evaluation.
    
COST/TECHNICAL TRADEOFF AND AWARD DETERMINATION
    
In the first instance, Accurate asserts that the agency failed to give
sufficient weight to its proposed low cost, based on Accurate*s alleged
belief that cost would be the evaluation driver because of the ALVIN
project*s emphasis on cost savings.  Protester*s Comments at 14-15.  
    
In deciding between competing proposals, cost/technical tradeoffs may be
made, the propriety of which turns not on the difference in technical
scores or ratings per se, but on whether the source selection official's
judgment concerning the significance of the difference was reasonable and
adequately justified in light of the RFP evaluation scheme.  DynCorp,
B-245289.3, July 30, 1992, 93-1 CPD P: 69 at 8.  Even where a source
selection official does not specifically discuss the cost/technical
tradeoff in the source selection decision itself, we will not object if
the tradeoff is otherwise reasonable based upon the record before us. 
Digital Sys. Group, Inc., B‑286931, B-286931.2, Mar. 7, 2001, 2001
CPD P: 50 at 11-12.  The primary emphasis that Accurate would have the
agency place on cost is inconsistent with the RFP criteria here, which
made cost one of the less important factors, and provided that technical
considerations were substantially more important.  Similarly, while
Accurate objects that the agency placed great emphasis on past performance
and risk, this emphasis is consistent with the RFP evaluation scheme which
makes past performance and proposal risk the most important evaluation
criteria.  There is no basis to require the agency to afford greater
weight to cost, or less weight to past performance or proposal risk than
is provided for by the RFP evaluation criteria.
    
As detailed above, the SSA gave primary focus in his award determination
and the underlying cost/technical tradeoff to a comparison between the
Raytheon and [deleted] proposals because of the closeness of their
evaluations, and the fact that Accurate*s proposal was evaluated as a
distant third.  This documentation set forth specific examples of
Raytheon*s superiority under all of the non-cost factors and, consistent
with the RFP, of offered features that exceeded the RFP*s stated goals. 
The record also establishes that in addition to its lower past performance
assessment, Accurate*s proposal received a lower evaluation than
Raytheon*s under proposal risk, the other equally weighted most important
evaluation factor.  Raytheon*s proposal received uniformly low risk
evaluations under all three proposal risk subfactors.  In this regard, the
SSA explained that *one of the biggest risks we have in flight test is
safe separation from the aircraft when its launched in jettison [and
Raytheon] had proposed a [deleted] that was going to safely remove the
MALD from near the aircraft in its deployment phase.  And that would have
really lowered our risk in flight test; to make sure this thing can safely
get away from the airplane.*  Tr. at 233-34.  Further, the engine design
proposed by Raytheon had been successfully tested during such airborne
deployment.  In contrast, Accurate*s proposal risk was evaluated as
moderate under the point of departure design subfactor primarily because
of its relatively new and partially untested engine design.  Accurate*s
proposed engine had not been tested for airborne deployment, and the
agency*s experience had been that a significant amount of testing was
required to get the MALD engines to start at a high altitude for such
deployment.  Tr. at 191.  Further, as noted above, the SSA determined that
the need for additional testing and other likely delays associated with
Accurate*s proposed engine design raised a significant risk that
Accurate*s evaluated cost savings would be illusory.  Accurate has not
provided any credible basis to call into question this risk assessment. 
In sum, the record establishes that the cost/technical tradeoff and award
determination are reasonable, consistent with the RFP evaluation criteria
and adequately documented with respect to the Raytheon proposal vis-`a-vis
the Accurate proposal.
    
The protest is denied.[6]
    
Anthony H. Gamboa
General Counsel
    
    
    
    

   ------------------------

   [1] The MALD, which weighs on the order of 200 pounds and is approximately
the size of a typical air-to-air missile, is intended to be carried on
F-16, B-52 and other aircraft  and to be launched while airborne in order
to create the impression that the decoy is a fighter or bomber aircraft. 
The MALD is intended to provoke a response which will reveal or occupy
enemy air defenses and enable the Air Force to saturate and suppress an
integrated air defense system without exposing real aircraft to detection
and attack.  Contracting Officer*s Statement at 1; Agency Report (AR),
Memorandum of Law, at 2.  As part of the agency*s identification of
requirements for the MALD effort, prior to issuing the RFP it awarded five
air-launched vehicle investigation (ALVIN) contracts to five separate
contractors, including Raytheon and Accurate, to perform 90-day studies of
*cost as an independent variable* tradeoffs within the existing
requirements and to clarify the industry*s capabilities; the Air Force
used the results of these studies to help determine what was possible and
at what potential cost.  Contracting Officer*s Statement at 1; Hearing
Transcript (Tr.) at 70.        
[2] Accurate has not questioned the agency*s probable cost determination. 
In performing its probable cost calculations, as explained by the SSA (and
consistent with the record) the agency did not make any adjustments for
anticipated delays or other additional costs associated with performance
risk.  As the SSA testified, the agency*s probable cost estimate *assumes
that the program is going to go as the contractor proposed,* Tr. at 273,
and *assumes that all goes as planned in the program.*  Tr. at 237-38. 
However, both the chief of the technical evaluation team and the SSA
explained that they believed that the relatively greater evaluated risk
specifically associated with the Accurate proposal, particularly with
respect to its partially untested proposed engine, was likely to result in
additional flight testing and delays that would increase the actual
performance cost under Accurate*s proposal by many millions of dollars. 
Tr. at 161, 273, and 274.   
[3] [Deleted] overall proposal risk and mission capability evaluations
were substantially equal to Raytheon*s; its past performance subfactor
evaluations were slightly lower, consisting of very good/significant
confidence under subcontractor management and exceptional under the other
two subfactors. 
[4]In explaining the rationale for his determination to have the RFP place
the greatest weight on the subcontractor management subfactor, the SSA
testified that the  predecessor MALD program had been terminated because
of failures that included large schedule slips and large cost overruns
that had resulted in significant measure from poor management of
subcontractors.  Tr. at 211, 222-23.
[5]Accurate submitted information concerning [deleted] SBIR contracts in
its past performance volume.  These contracts were relatively small in
size and limited in scope, and did not qualify as programs eligible for
past performance evaluation under the RFP.  However, in an effort to
ensure that Accurate received a fair evaluation, the PRAG bundled the 20
most relevant of these SBIR contracts together and considered them a
*program* for evaluation purposes.  Contracting Officer*s Statement at 6;
Performance Evaluation Chief*s Testimony, Tr. at 296-97. 
[6] This decision has addressed the primary arguments presented by
Accurate*s protest.  In addition, Accurate raised a number of collateral
issues that we have considered and find without merit, but which do not
warrant detailed analysis or discussion.